The opinion
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
STANLEY HAMILTON CIVIL ACTION
VERSUS CASE NO. 25-924
NATIONAL COLLEGIATE ATHLETIC SECTION: “G”(5)
ASSOCIATION
ORDER AND REASONS
Before the Court is pro se Plaintiff Stanley Hamilton’s (“Plaintiff”) Motion for
Reconsideration on Motion for Temporary Restraining Order.1 Plaintiff, a student athlete at
Southeastern Louisiana University, brought this action under the Sherman Act against the National
Collegiate Athletic Association (“NCAA”), alleging that he is entitled to four seasons of eligibility
in track and field.2 On June 3, 2025, Plaintiff filed a Motion for Temporary Restraining Order
seeking injunctive relief preventing the NCAA from enforcing its eligibility rules, which Plaintiff
asserts would preclude him from participating in collegiate track and receiving scholarship
benefits.3 On June 6, 2025, the Court denied the motion, finding that Plaintiff had not met his
burden pursuant to Federal Rule of Civil Procedure 65.4 On July 22, 2025 Plaintiff filed a Motion
for Preliminary Injunction, which is set for hearing on August 21, 2025.5 On July 29, 2025 Plaintiff
1 Rec. Doc. 30.
2 Rec. Doc. 1.
3 Rec. Doc. 17.
4 Rec. Doc. 18.
5 Rec. Doc. 24.
filed the instant motion for reconsideration.6 On July 30, 2025, the Court held oral argument on
the motion. Considering the motion, the record, the applicable law, and the oral argument, the
Court finds that Plaintiff has not demonstrated entitlement to the extraordinary relief of
reconsideration or the issuance of a temporary restraining order.
Federal Rule of Civil Procedure 65 governs injunctions and restraining orders, and Rule
65(b) sets forth the procedural rules governing the issuance of temporary restraining orders. In
order to obtain a temporary restraining order, a plaintiff must establish the following essential
elements: (1) a substantial likelihood of success on the merits; (2) a substantial threat that failure
to grant the injunction will result in irreparable injury; (3) the threatened injury outweighs any
damage that the injunction will cause to the adverse party; and (4) the injunction will not do
disservice to the public interest.7 This Court previously denied Plaintiff’s motion for a temporary
restraining order finding, in part, that Plaintiff failed to demonstrate a substantial likelihood of
success on the merits.
Plaintiff seeks reconsideration of the Court’s Order denying the temporary restraining
order. A motion for reconsideration “is not the proper vehicle for rehashing evidence, legal
theories, or arguments that could have been raised before the entry of judgment.”8 Instead, it only
served to correct manifest errors of law or fact to present newly discovered evidence. Plaintiff still
has not established a substantial likelihood of success on the merits.
6 Rec. Doc. 30.
7 Janvey v. Alguire, 647 F.3d 585, 595 (5th Cir. 2011).
8 Templet v. HydroChem Inc., 367 F.3d 473, 478–79 (5th Cir. 2004).
Subject to NCAA Bylaw 12.8, also known as the “Five-Year Rule,” a student-athlete has
five years during which to play four seasons of a given sport. The five-year clock starts to run on
the date when the student-athlete registers as a full-time student. Plaintiffs five years presumably
ran in 2024, five years after he enrolled in college in 2019. Although the NCAA may grant an
extension of eligibility based on demonstrated hardship, Plaintiff has not provided sufficient
evidence to establish such a hardship. Without proof of a qualifying hardship, Plaintiff is subject
to the five-year rule, and the NCAA’s enforcement of this rule does not appear arbitrary or
unlawful. For these reasons, Plaintiff has not demonstrated that he is entitled to reconsideration of
the June 6, 2025 Order denying Plaintiff's Motion for a Temporary Restraining Order.
Accordingly,
IT IS HEREBY ORDERED that Plaintiff's Motion for Reconsideration on Motion for
Temporary Restraining Order? is DENIED.
NEW ORLEANS, LOUISIANA, this 31st day of July, 2025.
Dorcel Jobuvett Ui.
NANNETTE JQEIVETTE BROWN (ow?
UNITED STATES DISTRICT JUDGE
Rec. Doe. 30.